City of Chicago v. Westforth Sports, Inc.

Illinois Appellate Court
Civil Court
Jurisdiction
Citation
Case Number: 
2025 IL App (1st) 231908
Decision Date: 
Friday, March 14, 2025
District: 
1st Dist.
Division/County: 
6th Div./Cook Co.
Holding: 
Reversed.
Justice: 
HYMAN

Plaintiff filed a lawsuit against defendant, a federally licensed, Indiana-based firearms dealer alleging that the defendant knowingly facilitated straw purchasers of firearms and seeking injunctive and monetary relief. Defendant challenged the state court’s jurisdiction, arguing that it lacked minimum contacts with Illinois and that the city’s claims were too remote from its conduct. The trial court agreed and plaintiff appealed. The appellate court reversed, finding that the city sufficiently alleged that the defendant deliberately and purposely availed itself of the Illinois market and was fully aware of the harms that the firearms would contributed to criminal activity in the city and that these alleged harms with neither incidental nor accidental. (TAILOR and C.A. WALKER, concurring)